Today the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) settled violations of the Iranian Transactions Regulations (“Regulations”) with the ATP Tour, Inc. (“ATP”) who they allege violated §§ 560.206 and 560.208 of the Regulations by approving, facilitating, and in some instances making, 18 salary payments to an individual who is ordinarily resident in Iran (the “individual”), for services rendered and expenses incurred in connection with ATP tournaments the individual officiated.
ATP did not self-disclosure their violations to OFAC. For more information on filing a voluntary self disclosure of OFAC violations please see my article at: http://www.avvo.com/legal-guides/ugc/top-three-tips-for-filing-an-ofac-voluntary-self-disclosure
The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. If you have any questions please contact him at 202-280-6370 or ferrari@ferrariassociatespc.com.